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European Court fines Malta over delayed marriage registration

The European Court of Human Rights has fined Malta €6,000 for a delay of almost three years in the registration of a marriage between a Syrian-born Maltese citizen and a Russian girl.

The case involved Mazen Dadoush, who was granted Maltese citizenship in 1993 in consequence of his marriage to a Maltese national. Subsequently, on 22 March 2002 the marriage was annulled by court order as it had been found to be a marriage of convenience. However, the applicant retained Maltese nationality according to the law in force at the time.

On 30 July 2003, Mr Dadoush married a Russian national in Moscow.

In the days following 30 June 2004 he applied to the Public Registry Office to have his marriage registered in Malta but that recognition was only given nearly three years later after court proceedings in Malta.

The European Court was told that on several occasions, notwithstanding the presentation of his Maltese identity card and a Maltese passport, the Maltese Public Registry required “as a matter of policy” that the applicant submit a letter from the Department of Citizenship declaring that he was a citizen of Malta.

According to the Maltese government the authorities also noted that the requisite translation of the Russian marriage certificate presented by the applicant had not been apostilled by the Ministry of Foreign Affairs of Moscow.

Despite his contention that the request for a letter from the Department of Citizenship did not have a legal basis in domestic law, Mr Dadoush requested the Department to issue the letter. The head of department refused to issue such a letter, allegedly replying that he was not bound to issue it then, if at all.

Following Mr Dadoush’s request, by a decision of the Court of Revision of Notarial Acts dated 31 May 2005, the Director of the Public Registry was directed to register the marriage, upon the applicant submitting his original act of marriage in Russian together with an English translation authenticated by his lawyer.

The applicant’s request remained unsatisfied notwithstanding this decision.

On 5 April 2006 the decision of 31 May 2005 was revoked by the Court of Appeal. The latter, while expressing doubts as to whether the applicant could apply to the Court of Revision of Notarial Acts, held that a Maltese passport was not conclusive evidence of citizenship. Furthermore, the Director was vested with discretion to demand documents which he considered reasonable to prove the authenticity of what was submitted to him.

The Maltese court therefore agreed that the Russian certificate of marriage produced by the applicant was not sufficiently authenticated evidence satisfying the Director of the Public Registry.

On 20 June 2005 Mr Dadoush instituted proceedings before the Civil Court (First Hall) in its constitutional jurisdiction. He complained that the refusal to register his marriage was in violation of his Article 8 rights alone and in conjunction with Article 14.

The Public Registry gave two reasons for the refusal to register the marriage. Firstly, the documents presented by Mr Dadoush had not been authenticated by the Ministry of Foreign Affairs of Moscow, which was the competent authority to attach apostilles to such public documents, and, secondly, that every person who applied for registration was asked to produce a letter of citizenship.

On 2 May 2006, during these proceedings, the Head of the Nationality Department confirmed that the applicant was a Maltese citizen.

On 10 October 2006, the court rejected the application, with legal costs to be paid by Mr Dadoush.

It held that his rights had not been breached, since the Director of the Public Registry had not categorically refused to register the marriage, but had merely requested appropriate documentation. Moreover,the law did not extend to a general obligation on the part of a Contracting State to respect the choice by married couples of the country of their matrimonial residence and to accept the non-national spouse for settlement in that country.

On 11 October 2006, Mr Dadoush appealed to the Constitutional Court.

Meanwhile, on 9 November 2006, the applicant was called upon by the Registry to register the marriage. He was asked to submit the original or an authenticated copy of his marriage certificate. No further documents were requested.

On 13 November 2006 the marriage was registered on the basis of the documents originally submitted by the applicant.

On 9 March 2007, the Constitutional Court found that there had not been a violation of Article 8 of the Convention. It held that the request for a “letter of citizenship” was in accordance with law as the Director of the Public Registry had to be satisfied that at least one of the parties to the marriage was a Maltese citizen. Although an identity card and a passport were prima facie evidence of nationality they were not conclusive, especially when citizenship had been obtained through registration (as in the case of the applicant) or naturalisation, both being subject to revocation according to section 14 of the Maltese Citizenship Act.

However, the Constitutional Court noted that from the witness testimony at the hearing of 2 May 2006, it was clear that the applicant was a Maltese citizen; however, interdepartmental lethargy had meant that the Director of the Public Registry only called upon the applicant to register the marriage on 9 November 2006. Thus, the Court revoked the first-instance judgment in part by ordering the costs to be shared between the parties.

Mr Dadoush in his application to the European Court, said tha the refusal to register his marriage based on a request for a letter of nationality was an interference which was not in accordance with the law and not necessary in a democratic society.

The Maltese Government submitted that the fact that a marriage did not qualify for registration according to the Civil Code did not necessarily mean that it would not be recognised as a valid marriage since section 18 of the Marriage Act would then be applicable (see relevant domestic law).

The government alleged that registration had no effects for the purposes of law. Allowing registration of marriages contracted outside Malta only served practical purposes, in that the relevant departments would not require further proof when presented with certificates authenticated by the Public Registry. They added that the Government did not contest the marital status of persons marrying abroad and that registration of the marriage was not a requirement for the application of the relevant provisions of the Immigration Act, Social Security Act or Tax Act.

Moreover, the government submitted that there had not been any interference with the applicant’s private and family life. Although there was no right to establish a family in any particular jurisdiction, the applicant was allowed to continue to reside in Malta and to cohabit with his spouse.

The fact that the Maltese authorities insisted that the conditions laid down by domestic law for the registration of a marriage celebrated by a Maltese citizen abroad had been satisfied could not amount to an interference. Indeed, once the authorities had acquired proof of citizenship through the deposition of one of the witnesses from the Citizenship Department and had verified the authenticity of the marriage certificate with the Maltese Embassy in Russia the applicant’s marriage was then duly registered.

The European Court said that it was primarily for the national legislation to lay down rules regarding the validity of marriages and to draw the legal consequences. The same was true of procedures relating to the registration of such marriages.

The court noted that apart from the issue as to whether the documents submitted by the applicant fulfilled formal requirements, the government had not given any reason justifying the need in a democratic society for refusing registration of the applicant’s marriage for over two years.

In the present case, even assuming the marriage act itself required further verification, the court considered that the need to study the Hague Convention to verify whether the marriage certificate had been apostilled or, alternatively, to carry out further checks with the relevant embassy, as was eventually done by the government, could have been conducted in a more timely manner.

Similarly, as regards the certification of the applicant’s citizenship, the court was of the view that since the applicant was in possession of a valid Maltese passport, a presumption of his Maltese nationality arose. It considered that in circumstances where a person’s nationality was certified by means of his or her passport, the onus of proving that the information contained in their passport was not conclusive of nationality shifted to the authorities.

Thus, if the authorities believed that the applicant might have renounced his Maltese citizenship, it was for them to verify the matter with the relevant department and within an appropriate time-frame, rather than to require the holder of a valid Maltese passport to prove that he still retained Maltese nationality.

However, even assuming that it was acceptable to request corroboration of such evidence in the case of citizenship obtained through registration (as in the case of the applicant) or naturalisation, the court said that it did not accept that such corroboration necessitated such a considerable delay.

It notes that the delay persisted during the domestic proceedings and verification was eventually satisfied through the witness testimony of a person working in the relevant Government department.

The Court further observed that the applicant had attempted to obtain a letter of citizenship, notwithstanding the precarious legal basis for such requirement, but the authorities refused to issue such a letter.

The European Court therefore rejected the government’s argument that the delay was due to the applicant’s decision to institute proceedings.

The Court finds that the denial of the registration of the applicant’s marriage for a period of over two years was a disproportionate interference with the rights of Mr Dadoush.

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Robert Azzopardi

Jul 22nd 2010, 11:47

Ok Reuben lets get this straight. I do not think that every Maltese person is racist, that would imply that I am as well, not to mention that I know quite a few people that certainly arent. The biggest issue in fact is not Maltese being racist but the superiority feeling that they seem to have. There is truth in what you say regarding people overstaying visas, but my problem begins only when I see the attitude of certain people in Malta towards anybody who is not Maltese. Stigmas run really deep in Maltese society. I have personally indirectly experienced and witnesssed a lot of discrimination and a lot of condescention. I do not feel the need to share it here but I can assure you that it came from peopel you least expect it from. I do not necessarily blame the people themselves but I do blame society and the political elite who choose to keep the general public ignorant on so many issues. Ultimately I'm sorry to disappoint you but the result will still be the same whichever way you look at it, the largest percentage of the Maltese population is intolerant.

Patrick Sacco

Jul 22nd 2010, 11:25

"I have the rubber stamp. I decide if and when to use it ! Your rights, Mr Citizen, are not my duty !"

I agree 100% with you Dr. Brincat on this issue. In fact, some Maltese so-called civil so-called servants simply treat us like trash. They don't help you at all, which after all is their duty!
Sometimes, you even see them sneering, almost sadistically at you as if they are taking pleasure in making your life a hell.
If Mr. M.D.'s case was a case of bureaucratic crucifixion, then it is the Civil servant/s in question who should pay the €6,000.

"The Nullity judgment was based i on lack of maturity of both parties. (Article 19(1)(d) of Marriage Act)."

To be honest I still find this somewhat hard to digest!

Robert Azzopardi

Jul 21st 2010, 18:18

Yes sure, this online forum to begin with. Just talk to pretty much anybody about sub-saharan Africans, Arabs or Eastern Europeans and you'll get bascially the same response.

Christian Sciberras

Jul 22nd 2010, 00:26

Roses are red, violets are blue. So what?

John Micallef

Jul 21st 2010, 15:45

Ms Green,
It's only human that a nation protects itself from such people!! Be realistic pls.

Im just coming from Italy and hostility is every were from the bus, to the church. In UK in a shopping mall i have seen 2 arests for theft in 4 hrs. What else

Such people are found every were, and for sure even in the country you come from. But unfortunatley the bad is made news & the good burried. Come to our streets in Tarxien & Paola. At any given time of the day there is always someone helping a tourist in to find the way to our lovely temples.

If you are well educated yourself pls do not re-generate when you talk, as for sure you met good people in Malta that are always ready to help?! Don't anwer me.

C. Green

Jul 21st 2010, 16:07

As I said earlier in my comment:

I DO PITY THOSE HONEST MALTESE WHO ARE ASHAMED FOR THE
BEHAVIOUR OF THEIR COMPATRIOTS.

I also don't understand what arrests for theft have to do with xenophobia.
But then I'm only a "stupid foreigner" as we have heard people call us and others on the buses - one who you can give false change back, one you can charge twice the price for market stall products than you'd charge a Maltese, one you can comment on derogatively.

Sure there is xenophobia elsewhere, too. But instead of being ashamed of officials harrassing foreigners, people here go on about the EU taking control out of their hands!

What a shame the EU will protect individuals' rights against the apparently NATURAL RIGHT of the Maltese to harass them!

J Galea

Jul 21st 2010, 20:27

Re:- C.Green i do feel sorry cause many times i've been told that the British are the worst liked nation in Malta and Gozo, why only God knows, my wife happens to be Welsh, and very often she was mistaken for English and charged the usual extra, two prices one for the outsiders and t'other for the locals. I also speak Maltese with a Canadian accent but enough to fight back and tell them what i think of them, its got so bad that now so much so that in due course we will be leaving Gozo where we have been residing for the past 3 years and go back, the only problem is trying to sell our property which is NOT EASY nobody wants to know now a days least of all the British due to the bad economy in the UK, but we just haver to sit tight till we sell up and move out much sooner then later even at a reduced figure. in otherwords we've had it with this country sorry to say, its been good while it lasted. Gharb(gozo)

Christian Sciberras

Jul 22nd 2010, 00:24

M(r)s Green, no need for pity. I'm pretty proud I don't flow like the rest...
Personally, there's always something interesting to learn even from the worst foreigners, too bad some people find it comfortable living in their own little cosmos.

Robert Azzopardi

Jul 21st 2010, 18:21

Dear Fenech, just please do us a favour, read up a bit and then comment. You don't even need extensive reading on the subject, just read the post just below yours.

Franco Farrugia

Jul 21st 2010, 19:18

@ Joe Vella et al: some points are worth clarifying. If you think that Malta will ever leave the EU, forget it. If it had to come to that, which it will not, ever, there will be so much money that we would have to pay back that we would go bankrupt completely!
Thank goodness we are members of the EU. Only troglodytes and outdated cavemen still yearn for a time when Malta will not be in the EU. I mean, listen to you old moaners ... everytime anything with Europe is mentioned, you immediately start crying foul, against the EU. There is so much ignorance in this country. So much lack of reading, so much lack of understading. Pleaaaaaaaaaaaase, I implore you, do not show off your ignorance and lack of ability at simple comprehension.

Robert Azzopardi

Jul 21st 2010, 13:02

David, unfortunately the answer is yes people ARE that THICK! ysther that or they simply choose to acknowledge basic facts. Not to mention that Maltese love populist rhetoric! In addition nobody has ever bothered explaining to them what the EU really is what the ECHR really is what the ECJ is what the Council of Europe is. The reason is also simple, everybody twists and turns things to gain political mileage. PS do not forget the other truth that Maltese always think that they are right and the rest of the world is wrong.

Peter Spiteri

Jul 21st 2010, 13:12

Mr Mark Galea, then perhaps those who do not believe in European Union membership may send their message at election time through their votes as their only means of sending their message to the political parties?

J.Spiteri

Jul 21st 2010, 12:13

Thats nothing sunshine the worst is still yet to come, i am Maltese by birth living in Holland, and i can tell you right now we moan in Malta but byJoe we don't even realize how lucky we are as comparing our country with Holland and the UK, there is a tax or a fine for just about everything under the sun, unfortunitly our little island is following their way of life....a shame for democracy and the Maltese people. In the netherlands they have a habit of giving us extra in our pensions or tax rebates then a year or so later they ask for it back in a lump sum due to their incompetance, and that is Dutch way of doing things>Dish it out with oine hand and grab it at a later date with the other, pensioners or not its the regels(law) as they say

Maria Azzopardi

Jul 21st 2010, 12:26

Malta is a racist country and if it needs to learn its lesson through fines then so be it

Robert Azzopardi

Jul 21st 2010, 13:08

maria i totally agree

Laura Falzon

Jul 23rd 2010, 13:19

agree 100% with Maria. At the school of my children there are a couple of kids that got adopted from Ethiopia. You cannot immagine how some of the children and parents they threat them !! sometimes I'm ashamed to be white .....

Joseph Micallef

Jul 21st 2010, 12:01

This is the Malta which has been like this since 1965 - the EU has nothing to do with the European Court!!

Joe Bonnici

Jul 21st 2010, 13:16

JOe VELLa although in this case the court is not that of the eu, I agree with you that when the time comes we shall be at the forefront and reclaim our country back from the eu petty dictators colonialists for yes, we have again become a foreigners colony, this time of the eu colonialists.

R.Gauci

Jul 21st 2010, 10:44

Just to let you know that the Law changed on don't know exactly which year, but from that time onwards people from Non EU countries which got married to Maltese have to wait five years to get a Maltese Citizenship!

Marcel Dingli

Jul 21st 2010, 10:53

U ma tarax . Tighten the belt ? U l kuxjenza ta Gonzi insejtha, li skond kuxjenzthu l barranin jigu qabel il Maltin.

RMangion

Jul 21st 2010, 10:36

Mentalita purament Maltija. Tohrog mill EU ghax qed tiftahlek ghajnejk u tghidlek hemm ligijiet u trid issegwihom ?

X'Tipretendi mela, li kulhadd (inklus il-Gvern) jaghmel li jrid jew ?

David Buttigieg

Jul 21st 2010, 10:43

The EU has nothing to do with the ECHR, we have fallen under ECHR jurisdiction since 1965!!! We would still have to abide by it's rulings were we not members of the EU!

Joseph Micallef

Jul 21st 2010, 11:59

Qed jispjegawlkom li il-Qorti Ewropea m'ghandhiex x'taqsam mal-EU u ha tibqghu izzeffnu l-EU? Qed nikteb bil-Malti forsi tifhmu fl-ahhar!

Robert Azzopardi

Jul 21st 2010, 12:13

dear mr buttigieg. Forget trying to explain simple facts to knuckle heads, they just refuse to listen. You are of course absolutely right the EU and ECHR are separate entities but you will fail if you try explaining it to total injuranti. Give up my friend qed taghzaq fl ilma unfortunately

David Buttigieg

Jul 21st 2010, 13:07

@Robert Azzopardi

You make a good point!

Joe Bonnici

Jul 21st 2010, 13:46

RMangion fil-każ tal-eu liġijiet li ma jgħoddux għalina. Issa mhux il-Maltin biss qed jgħidu li l-politika one-size-fits-all tal-eu mhix tajba, imma anki barranin.

Christian Sciberras

Jul 22nd 2010, 00:20

Joe Bonnici - Jimporta ma tikkumentax minghajr ma taf x'int tghid?

Stephen Koludrovic

Jul 21st 2010, 10:43

Yes since she was an accomplice in the fraud.

G Schembri

Jul 21st 2010, 10:25

M'ghandu x'jaqsam xejn ma l'EU!

Franco Farrugia

Jul 22nd 2010, 08:32

Dan kollu m'ghandu xejn x'jaqsam mal-UE.
Inqas kliem, u iktar qari u studju.
U iva, nehduha, l-UE. Jien qed ingawdi minnha, u int?
Kif tista' ma tgawdix, fl-UE?

David Buttigieg

Jul 21st 2010, 10:17

My goodness Mr Vella,

Are you really that ignorant? What in God's name has the European Court of Human Rights got to do with the EU? Malta has fallen within the ECHR jurisdiction since 1965 in it's own right. The EU is not even a member itself!

Think, THINK before you speak!

lgalea

Jul 21st 2010, 10:29

David Buttigieg presently the eu is not, but it is on the way to become a member.

David Buttigieg

Jul 21st 2010, 10:41

Agreed Laurence,

But the point made is that the EU and the ECHR (are completely different entities!

Joann Bugeja

Jul 21st 2010, 09:37

because his first marriage was with a Maltese national....

Tommy Lee

Jul 21st 2010, 09:39

Second paragraph.

The case involved Mazen Dadoush, who was granted Maltese citizenship in 1993 in consequence of his marriage to a Maltese national. Subsequently, on 22 March 2002 the marriage was annulled by court order as it had been found to be a marriage of convenience. However, the applicant retained Maltese nationality according to the law in force at the time

lgalea

Jul 21st 2010, 09:44

Joann Bugeja In that case his Maltese citizenship should have been revoked because it was proven beyond any reasonable doubt that his marriage with a Maltese citizen was only a sham marriage in order to get Maltese citizenship. Now not only do we have a Maltese wife who was abandoned but a Syrian given Maltese citizenship married again to a Russian who will also get Maltese citizenship because her husband has Maltese citizenship. Maltese citizenship has been thrown to the dogs. Apart from this, was his marriage with the Maltese wife annulled and if so why was he not stripped of Maltese citizenship? If his marriage was not annulled, how can he be married again? This would be bigamy.

Stephen Koludrovic

Jul 21st 2010, 09:52

And it was a simple marriage of convenience, just money changing hands for the certificate.
IMO if the marriage was a fraud, then his citizenship was also gained by a fraud.

Sean Grima

Jul 21st 2010, 10:35

the reply to your questions is in the article itself:

1. the marriage was annulled by court order as it had been found to be a marriage of convenience: therefore no issue of bigamy as he was not married at the time he contracted the 2nd marriage

2. the applicant retained Maltese nationality according to the law in force at the time: whether we like it or not, that was the law at the time. it is not what "should" be done (i.e. in our opinion) but what the law is in fact.

Christian Sciberras

Jul 22nd 2010, 00:14

lgalea - Yep, everyone is begging me to somehow sell them my Maltese Citizenship.....

Ramon Casha

Jul 22nd 2010, 05:34

I agree that citizenship acquired based on a marriage of convenience should be revoked, but that fact is that it wasn't. Therefore he is a citizen, and the ECHR is right in its sentence - three years to register a citizen's marriage is way too long. If anything, your complaints should be directed at the law which allows him to retain citizenship when it was acquired fraudulently.

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